New Punitive Damage Decision From 6th Circuit

The 6th Circuit Court of Appeals has cut a punitive damage award in a products liability case. A jury determined that the defendant produced a defective product that caused the death of the occupant of it. The jury awarded, and the trial judge affirmed, a $3,000,000 punitive damage award.

The appellate court cut the punitive damage award to $471K (200% of the compensatory damage award) and summarized its reasons for doing so as follows: “an application of the Gore guideposts to the facts of this case reveals that (1) Chrysler’s misconduct does not constitute a high degree of reprehensibility, (2) the ratio of punitive to compensatory awards is unjustifiably large, and (3) a wide gap exists between the punitive damage award and comparable civil penalties. The fact of Mr. Clark’s death does not outweigh all.”

Judge Moore dissented, saying “Chrysler’s conduct was reprehensible, the ratio between the punitive and compensatory damages awards was neither breathtaking nor otherwise unreasonable given the circumstances of the case, and the punitive damages award was in line with comparable civil penalties ….”